Portugal's new building code (RJUE) in force since 1 October 2026: what changes for installing a mobile home
By Matheus Agueda · 3 October 2026
What happened on 1 October 2026
Decree-Law 108/2026 of 29 May revised Portugal's building and planning code (RJUE, Decree-Law 555/99) to fix the application problems of the 2024 «Simplex Urbanístico» (Decree-Law 10/2024). It set its entry into force on the first working day of the third month after publication (art. 13(1)); according to the Diário da República note on the consolidated RJUE, the amendments took effect on 1 October 2026 under Decree-Law 155-B/2026 of 31 July.
For anyone installing a mobile home in Portugal the changes touch three things: how the prior communication (comunicação prévia) now works, how long the council has to intervene, and which control route applies to each case. What has not changed is the essential point: a mobile home installed with a permanent character is still an urban-planning operation.
The three control routes (article 4)
| Route | When it applies | How it takes effect |
|---|---|---|
| Licence (licença) | Construction, alteration or extension works outside the prior-communication cases | Council decision: 20 days for buildings (30 for urbanisation works, 45 for subdivisions) after the 20-day screening phase; no decision in time = tacit approval |
| Prior communication (comunicação prévia) | Operations where the urban parameters are already fixed: approved subdivision, detailed plan, consolidated urban area | Correctly instructed submission + payment of fees + notice of start of works; no admission phase |
| Prior communication with deadline (com prazo) | Use or change of use of a building without previously titled works (article 62-B) | Use may start 10 days after submission unless the council rejects it or orders an inspection |
Where prior communication applies, the applicant cannot opt for a licence instead.
The prior communication no longer has a 20-day wait
Until 30 September 2026 the prior communication went through a screening phase in which the council could respond within 20 days; many texts — including earlier versions of our guides — described it as «a reply within 20 working days with tacit approval».
Since 1 October the prior communication is a declaration under the responsibility of the applicant and the technicians. It takes effect in three steps: submission of the correctly instructed form, payment of the fees and other charges (self-assessment is allowed, with a payment deadline never shorter than 60 days) and the notice of start of works (article 80-A). The planning title is the proof of payment together with the submitted form (article 4-A); references to the alvará now mean the title of the operation (Decree-Law 108/2026, art. 9(3)).
In exchange, control moves to after the fact: the council's window for successive control of a prior communication is one year, counted from the payment of fees or, if later, from the start of works. During that year the council may ask once, with a 10-day deadline, for missing elements — otherwise the communication is deemed ineffective.
What this means for a mobile home
- Urban plot with fixed parameters (approved subdivision, detailed plan, consolidated urban area): the installation follows the prior communication. With the project and the technicians' liability statements ready, works may start once the fees are paid — no 20-day wait.
- Plot without fixed parameters: licence, decided within 20 days after screening, with tacit approval if the council stays silent.
- Rural land: the municipal master plan (PDM) still decides. Only with a compatible land-use class (rural tourism, campsite, tourist resort); on RAN land, construction is prohibited except for the uses in article 22 of Decree-Law 73/2009 (binding prior opinion of the regional RAN body, article 23), and on REN land, construction and extension works are prohibited except for the compatible uses in annex II (article 20 of Decree-Law 166/2008). Ask the council for a written prior information request before buying — the PIP now has express tacit approval.
- Licensed campsite or tourist resort: nothing changes — on a campsite, the unit is one of the park's complementary accommodation installations (Portaria 1320/2008, art. 19); in either case, confirm with the operator how the unit fits within their licence.
- Removable units: article 1-A of the RJUE was repealed on 1 October 2026 (Decree-Law 108/2026, art. 10). The RJUE treats as a «building» (edificação) any construction incorporated into the land with a permanent character, regardless of the construction system (art. 2(a)); whether your installation fits that definition is decided case by case by the câmara municipal — request an informação prévia (art. 14). Exempt from licence and prior communication are, among others, works of minor planning relevance (art. 6(1)(c)) — e.g. structures, attached or not, to the main building up to 2.2 m high (or the ground-floor eaves height) and 10 m² that do not border the public road, plus those so classified by municipal regulation (art. 6-A(1)(a) and (i)) — and operations preceded by a favourable informação prévia covering all the elements of art. 14(2) (art. 6(1)(h)); exemption does not waive plans, easements and public-interest restrictions or technical rules (art. 6(8)).
- A unit that remains a vehicle (wheels, towable, no fixed connections) is not a building, but it cannot serve as a permanent dwelling and parking it on rural land still depends on the PDM and the council.
And the IMI property tax?
While it is not entered in the property register (matriz predial), a mobile home pays no IMI. But the IMI code (CIMI, article 2(2) and (3)) treats as property (prédio) the constructions «even if movable by nature» used for non-transitory purposes and presumes permanence when they sit in the same place for more than one year. A mobile home lived in permanently can therefore be registered and taxed; for transitory use (holidays, site accommodation, seasonal lets) the advantage remains. More in the guide to removable homes in Portugal.
Checklist before buying the plot
- Land-use class in the PDM and constraints (REN, RAN, Natura 2000, easements).
- Prior information request to the council with the intended siting — written answer.
- Control route: prior communication (fixed parameters) or licence.
- Qualified technician for the project and the liability statements.
- Municipal fees under the council's regulation and, for tourist use, the local-lodging (AL) registration.
- Access for delivery and installation — see the installation guide.
Green Village advises each client on the framework in the municipality of installation and refers to local technicians when a project is required. For the European picture, see the country-by-country planning guide and the mobile home catalogue.
Frequently asked questions
Does the prior communication still get a reply within 20 working days? No. Since 1 October 2026 it takes effect with the instructed submission, the payment of fees and the notice of start of works. The council controls afterwards, for one year.
Does a mobile home need planning permission in Portugal? Installed with a permanent character, yes: a licence or a prior communication depending on the zone (article 4 of the RJUE) and the PDM. Article 1-A of the RJUE was repealed on 1 October 2026 (Decree-Law 108/2026, art. 10); whether your installation is a building — any construction incorporated into the land with a permanent character, regardless of the construction system (art. 2(a)) — is decided case by case by the câmara municipal: request an informação prévia (art. 14). On a campsite or tourist development, check with the park and with the câmara municipal how your unit is covered.
What is the prior communication with deadline? The route for using or changing the use of a building without previously titled works: use may start 10 days after submission unless the council rejects it or orders an inspection (article 62-B).
How much does it cost? The fees are set in each council's regulation and may be paid by self-assessment, with a deadline never shorter than 60 days after submission.
Can I install on rural land? Only if the PDM admits the use (rural tourism, campsite, tourist resort) and always with a licence or a prior communication. On RAN land only for the uses in article 22 of Decree-Law 73/2009, with a binding prior opinion when a licence or prior communication is needed (article 23); on REN land only for the compatible uses of article 20 of Decree-Law 166/2008.
Does a mobile home pay IMI? Not while it is outside the property register. The CIMI presumes permanence after one year in the same place, so a unit used as a permanent home can be registered and taxed.